Couple questions regarding SBR E-filing a Form 1

I signed in the ATF website and started my paperwork for a e-filed form 1. Got a couple questions

1. Do I have to upload a completed Cert of Compliance, ATF Form 5330.20, with the Trust upload or is it completed (or are you prompted to complete it) during the e-filing of the form 1
2. My build will be from a stripped receiver when approved. Do you list the stripped receiver by serial number in the trust schedule A. or wait  for approval then list it as a completed rifle in the trust schedule A.   Basically does the ATF want to see the stripped receiver in the trust as a asset at time of application?

Thanks for your help.

1. No. You only have to upload the trust. It has to be low resolution (I think less than 3mb).   http://johnpierceesq.com/?p=546

2.  You don't list the lower in schedule A until it is approved.

I assign any form 1 items that's are made from an existing firearm to my trust previous to submitting.

Ditto. It makes sense that if the trust is making an SBR from an existing firearm that the trust already owns said firearm.

This.

You could list the lower in Schedule A even though it's not technically correct, but why bother?  It's just another chance to f something up.

KEEP IT SIMPLE.

It is equally "technically correct" to list the lower or to not list the lower, as long as (in most states) the trust owns something.  There is no technical or legal reason that the lower shouldn't be listed on the Schedule A/owned by the trust at the time the Form 1 is filed, nor is there a technical or legal reason that it must be.

My interpretation regarding the stripped receiver was the same; list it or don't list it, either way as okay.  I was curious if recent e-file submits were being rejected or being returned for correction because it was or wasn't listed.

Hope to complete my e-filing form 1 today.

Thanks for your help.

The only copy of my Schedule A that the ATF has ever seen looks like this:




Every paper form and eForm...and all (20+) have been approved. Six more eForms pending right now, and that's the same copy that was sent in.

Thanks, btw that's exactly what mine looks like, $200 cash.

No, because the Form 1 you are submitting is the application to manufacture the SBR which is the lower; putting the lower in the Schedule before approved is not correct, but will be once approved and engraved.  Did you engrave before approval?  Oops.

Oh, well, why split hairs, the point is, and I'll say again, if there is no requirement to do so, and there isn't, then don't; it only complicates things and gives the applicant another chance to screw up (like putting down the wrong S/N or whatever).

I'll say this again, too:  for Pete's sake, KEEP IT SIMPLE.

Really? I thought you had to list everything that you had on the trust there. Maybe this is why mine always take forever....

I listed the lower I am going to SBR. I was advised to do so by a lawyer.

The Form 1 is an application to make (not manufacture) an SBR.  An AR lower is not an SBR, ever.  You already have the lower in hand.  You will be transferring it to the trust at some point (whether on paper or not) before the SBR is complete, because it's the trust that's got the tax stamp.  It is perfectly appropriate (though not required, as long as the trust owns something) to do that before you file the Form 1.  It's also perfectly appropriate to engrave it before approval.  Heck, you can engrave it before you file.  You can engrave it even if you never intend to file.  The only legal requirement on timing of engraving is that it be done before the SBR is assembled.

Because you're wrong.  And when you're wrong, you can expect to be challenged.  If you said you recommended against adding the lower to the Schedule A before you get the Form 1 back, no problem--you're entitled to your opinion, even if I think you're awfully concerned that someone might not be able to copy down a serial number correctly (after all, you can do it on the Form 1).  But when you say it's "not technically correct" to put the lower on the Schedule A before filing, you're wrong--just like you're wrong when you say that there's a requirement that you always be able to return an SBR to the Form 1 configuration.

They just want the trust to be valid. Keep the updated copy at home. No need to rescan a new copy each time.